Supplier/Vendor Code of Conduct
Compliance standards and ethical requirements for all vendors
Owner/Operator
Spyface Tech Company, LLC (d/b/a "ClinicBooking")
30 N Gould St Ste N, Sheridan, WY 82801, USA
Corporate: hello@spyface.com • Support: care@clinicbooking.com
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Scope & Who Must Comply
This Code applies to all suppliers, vendors, contractors, consultants, agencies, affiliates, resellers, and other third parties (collectively, "Vendors") that provide goods or services to, for, or on behalf of ClinicBooking (Spyface Tech Company, LLC), including data processors and technology partners. It is separate from our professional marketplace rules for clinics and clinicians; those participants must also comply with our Professional Participation and related policies.
Vendors must ensure that their employees, agents, and approved sub-suppliers who work on ClinicBooking matters comply with this Code and all contract terms. ClinicBooking may update this Code from time to time.
Legal & Ethical Compliance
- Anti-bribery & corruption: No bribes, kickbacks, facilitation payments, or improper benefits. Comply with FCPA, UK Bribery Act, and all local anti-corruption laws. Maintain accurate books/records reflecting all transactions.
- Anti-kickback / fee-splitting: No unlawful referral fees, fee-splitting, rebates, or inducements in connection with health services or listings. Marketing fees must be arm's-length and in writing.
- Fair competition & antitrust: No price-fixing, bid-rigging, market/customer allocation, or exchange of competitively sensitive information.
- Conflicts of interest: Disclose any actual or potential conflicts involving ClinicBooking personnel or decision-making processes. Gifts/hospitality: modest and infrequent; never cash; $100 USD per individual per year cap without written pre-approval.
- Accurate representations: No false, misleading, or unsubstantiated claims (including clinical, efficacy, or safety claims).
- Books & records: Keep complete, accurate records sufficient to demonstrate compliance with this Code and applicable law.
Labor & Human Rights
- No forced, trafficked, or child labor. Respect the prohibition on modern slavery and human trafficking. Comply with all wage, hour, and working-conditions laws.
- Non-discrimination & inclusion: No discrimination based on protected characteristics. Provide a workplace free from harassment and unlawful retaliation.
- Freedom of association: Respect lawful employee rights to organize and bargain collectively.
Health, Safety & Environment (HSE)
- Provide a safe, healthy workplace; comply with OSHA or local equivalents.
- Environmental compliance, including lawful handling/disposal of e-waste and hazardous substances; observe applicable standards (e.g., RoHS/REACH where relevant).
- Data center suppliers: disclose region/availability zones and high-level energy efficiency posture upon request.
Data Protection & Security
Vendors must comply with applicable privacy laws (e.g., U.S. state privacy laws, GDPR, UK GDPR) and ClinicBooking's data processing requirements. If Vendor processes personal data (including consumer health data) for ClinicBooking, Vendor must execute a Data Processing Addendum (DPA) and, where required, appropriate cross-border transfer mechanisms (e.g., SCCs/UK IDTA). PHI/HIPAA: If services involve PHI for ClinicBooking as a HIPAA Business Associate, a HIPAA BAA is required; otherwise Vendor must not solicit, store, or process PHI.
Minimum Security Controls (baseline)
Access control & MFA
Unique accounts, least privilege, MFA for admin and remote access.
Encryption
TLS 1.2+ in transit; strong encryption at rest for systems storing ClinicBooking data.
Secure development
OWASP-aligned SDLC, code review, dependency scanning; no training of AI models on ClinicBooking data without written approval.
Logging & monitoring
Retain security logs; monitor for anomalies; time-sync systems.
Vuln & patch mgmt
Prompt remediation per risk; critical/high CVEs addressed without undue delay.
Incident response
Written IR plan; notify ClinicBooking without undue delay and within 72 hours of discovering a breach affecting ClinicBooking data or systems.
Business continuity
Backups and tested recovery appropriate to service criticality.
Third-party risk
No sub-processors for ClinicBooking data without written approval and equivalent controls/agreements.
Assessments
Provide current SOC 2/ISO 27001 (or equivalent) upon request, or complete our security questionnaire.
| Control Area | Baseline Requirement |
|---|---|
| Access control & MFA | Unique accounts, least privilege, MFA for admin and remote access. |
| Encryption | TLS 1.2+ in transit; strong encryption at rest for systems storing ClinicBooking data. |
| Secure development | OWASP-aligned SDLC, code review, dependency scanning; no training of AI models on ClinicBooking data without written approval. |
| Logging & monitoring | Retain security logs; monitor for anomalies; time-sync systems. |
| Vuln & patch mgmt | Prompt remediation per risk; critical/high CVEs addressed without undue delay. |
| Incident response | Written IR plan; notify ClinicBooking without undue delay and within 72 hours of discovering a breach affecting ClinicBooking data or systems. |
| Business continuity | Backups and tested recovery appropriate to service criticality. |
| Third-party risk | No sub-processors for ClinicBooking data without written approval and equivalent controls/agreements. |
| Assessments | Provide current SOC 2/ISO 27001 (or equivalent) upon request, or complete our security questionnaire. |
Consumer Health Data (CHD): If Vendor may process CHD (e.g., under state laws like WA "My Health, My Data"), Vendor must implement heightened access controls, consent/choice handling, purpose limitation, and deletion mechanisms consistent with our directives.
Confidentiality & IP
- Protect ClinicBooking Confidential Information; use only for the contracted purpose; no unauthorized disclosure.
- Respect intellectual property and open-source license obligations; no unauthorized use of ClinicBooking marks.
- Return or securely destroy ClinicBooking data at end of engagement per contract.
Marketing & Communications Standards
- No spam or unlawful telemarketing (comply with TCPA, CAN-SPAM, CASL as applicable).
- No deceptive advertising, dark patterns, or unsubstantiated medical claims. Follow platform brand/badge usage rules.
- Affiliate/partner campaigns must use approved creatives, respect geo/state rules for healthcare marketing, and honor user opt-outs.
Sanctions, Export & Trade Controls
Vendor must comply with OFAC, U.S. Export Administration Regulations (EAR), and applicable EU/UK sanctions/export laws. Vendor represents it is not owned/controlled by, or acting for, a sanctioned party and will not route ClinicBooking goods/services to embargoed regions.
Subcontracting & Flow-Down
No subcontracting of ClinicBooking work or data processing without our prior written consent. Flow down this Code and all applicable contractual/privacy/security obligations to approved sub-suppliers and verify their compliance.
Insurance & Certifications
Commercial General Liability
$1,000,000 per occurrence / $2,000,000 aggregate
Professional/Errors & Omissions
$1,000,000 per claim (technology/professional services)
Cyber/Privacy Liability
$1,000,000 per claim (data breach costs, business interruption, network security)
Workers' Compensation
As required by applicable law
Additional Insured / Certificates
Provide COIs upon request; ClinicBooking may require to be named as Additional Insured where appropriate.
| Coverage | Minimum Standard (example baseline) |
|---|---|
| Commercial General Liability | $1,000,000 per occurrence / $2,000,000 aggregate |
| Professional/Errors & Omissions | $1,000,000 per claim (technology/professional services) |
| Cyber/Privacy Liability | $1,000,000 per claim (data breach costs, business interruption, network security) |
| Workers' Compensation | As required by applicable law |
| Additional Insured / Certificates | Provide COIs upon request; ClinicBooking may require to be named as Additional Insured where appropriate. |
Note: ClinicBooking may raise or waive limits based on risk and service scope.
Audits, Monitoring & Attestations
- Upon reasonable notice, cooperate with compliance reviews (questionnaires, documentation, remote or on-site visits).
- Provide timely responses to remediation findings and track closure.
Reporting Concerns & Non-Retaliation
Report suspected violations of this Code, law, or contract promptly to: hello@spyface.com. Retaliation against good-faith reporters is prohibited.
Remedies for Non-Compliance
- Corrective action plans, suspension of work, de-listing from our vendor roster, or termination for cause.
- Indemnification for losses arising from Vendor breach; other remedies available at law or equity.
Supplier Diversity & Sustainability
ClinicBooking encourages diverse suppliers (e.g., small, minority-, women-, veteran-, disability-owned) and sustainable practices (reduced waste, responsible sourcing). Vendors may be asked to report high-level ESG metrics relevant to the engagement.
Contact
Supplier & Compliance Inquiries
Email: hello@spyface.com
Support: care@clinicbooking.com
Address: Spyface Tech Company, LLC, 30 N Gould St Ste N, Sheridan, WY 82801, USA
